UKGC's Rhodes' CEO briefing: a mixed bag

Andrew Rhodes, CEO of the UK Gambling Commission (UKGC), delivered a speech to the CEO Briefing on 14 November 2024 in which he shared his visions for the British gambling industry.

The CEO Briefing event is a high-profile affair. As Rhodes put it, it’s “the only time of the year where so much of [the] British gambling sector are represented at a senior level in one room with the regulator”.

Amongst the main topics Rhodes touched on in his speech were the use of innovation in policy creation, the prevalence of illegal gambling, and shifting compliance levels. 

Key takeaways from Rhodes’ speech

Boost in compliance

Progress has been made in terms of industry compliance. Rhodes stated that, in the past, there had been a lack of consumer protection policies, as well as a lack of adherence to those policies that were in place. 

Rhodes claims that enforcements of operator policies have not always been “necessarily meaningful” but that they are now more strictly upheld. He suggests that the Commission’s new focus is on increasing the speed with which such interventions are made.

However, the overall standards of compliance are still low. In an assessment of consumer protection standards between April and June, only 42% of operators scored either ‘good’ or ‘satisfactory’ ratings.

Illegal gambling a major challenge

Illegal gambling is one of the biggest problems faced by the industry – for both the financial viability of legitimate operators, and in terms of safety for players. 

In his speech, Rhodes mentioned that such sites tend to appeal to self-excluded individuals, who are often deliberately targeted by black market operators. 

This remains the case, but Rhodes outlined a strategy that involved the UKGC collaborating with HM Revenue & Customs (HMRC) and the National Crime Agency (NCA).

Progress made

The UKGC issued 770 cease and desist orders and reported more than 100,000 URLs to Google in the period April-November 2024. This resulted in 264 websites being taken down. 

Illegal in-person gambling is another problem area. There have been a number of recent efforts to shut down such operations, one of which “involved 70 officers from one police force and led to several arrests and follow-up raids”.

Innovation and GamProtect

Rhodes highlighted the importance of innovation in achieving the Commission's goals. He cited the recently-launched GamProtect scheme as an example of a success in this arena.

GamProtect functions as a network between operators that holds data on self-excluded individuals. The system flags such individuals when they attempt to breach their exclusion, and has flagged more than 6,000 in the 2 months after its official debut.

Rhodes also expanded on a pilot system that was run during the year. It was intended to bridge communications between the regulator and the industry and “to provide opportunities for two-way operational collaboration”.

The pilot involved providing dedicated communications channels for use by operators, and has now come to a close. The UKGC will soon be considering whether to implement a similar system on a wider scale and on a permanent basis.

Gambling Survey for Great Britain a success

Not for the first time, Rhodes highlighted the uniqueness of the Gambling Survey for Great Britain (GSGB). It remains the largest survey of its kind anywhere in the world, and wields significant statistical power.

According to Rhodes, “the depth of information it provides is helping us push forward in a number of ways already.”

However, he also warned against comparing the GSGB’s data to that of its predecessor, the Health Survey, and made the case for the latter now being effectively redundant. 

Successes, limitations and interpretations

Communication, collaboration and transparency

The Commission has pledged greater levels of transparency around its own activities, enabling it to be held accountable, and for its actions and progress to be scrutinised.

‘Collaboration’ runs through Rhodes’ speech, and is even present in the organisation of the CEO Briefing event itself, which welcomed representatives from many areas of the industry. 

There’s little doubt that collaboration is the answer to finding balanced solutions that support consumer protection without stifling industry growth. An open and continuous discourse is the best way to reach mutually agreed conclusions. 

Also, this stated policy of openness and transparency seems to run contrary to some of the UKGC’s recent actions. For instance, it refused to release data from a survey regarding affordability checks that was later deemed to be in the public interest. This was assumed to be an effort to cover up the public backlash to the affordability checks revealed in the data.

These sorts of transgressions don't inspire confidence, and there is a whiff of hypocrisy surrounding Rhodes’ insistence on transparency, but if it marks an effort to right wrongs, then this should be welcomed.

The war on illegal gambling

Illegal gambling remains a significant obstacle for the Commission, and it’s a subject which has been receiving increasing amounts of attention recently.

Rhodes spoke positively about the success stories of recent months, and it’s certainly true that progress is being made. However, taking down websites is essentially just treating the symptoms while overlooking the root cause. The criminals behind these damaging operations remain free to create more brands, and illegal sites continue to pop up.

Unrelenting challenge

The Commission has its work cut out. Its influence and power are limited, and Rhodes’ speech even acknowledged the lack of data regarding illegal gamblers. The UKGC may well have reported over 100,000 URLs, resulting in 264 sites being taken down, but these figures suggest that any victory the Commission has enjoyed is little more than a drop in the ocean. 

Additionally, whilst Rhodes cites successful raids on illegal in-person gambling locations, it appears that we have very little knowledge of the prevalence of illegal land-based gambling. In the case of illegal online operators, the sites can be logged and monitored easily, but physical gambling locations may be underground and undetectable.

Increased regulation a double-edged sword

Furthermore, one of the main concerns about illegal gambling sites is how they benefit from over-regulation, as has been observed in other countries. Particular areas of concern include affordability checks and stake limits driving players to the black market. Rhodes’ speech makes no mention of how the UKGC plans to avoid a similar pattern emerging in Britain.

In some respects, it looks like the Commission is fighting a battle with one eye closed and one hand tied behind its back. This isn’t necessarily the Commission’s fault, and the victories should be acknowledged, but considering its limited power, collaborating with the police and HMRC simply might not be enough to win the war.

GamProtect off to a winning start

Although officially launched in September, GamProtect’s trial period began in February 2023, and it certainly seems to be working. 

GamProtect isn’t mandatory currently, and Rhodes provided no updates on whether this might change. Nevertheless, GamProtect does appear to be an effective tool for facilitating communication between operators and protecting self-excluded gamblers. 

Rhodes also mentioned the system’s ability to protect players without being intrusive. It is “fully compliant with data protection” and “can only be used to protect them”.

Health Survey vs GSGB

Rhodes and the UKGC have now asserted many times that data from the GSGB should not be compared with that from the outdated Health Survey. 

This is fair enough, but the question remains: What can we compare it against? With no reference points, a new data set compiled with a new methodology has limited applications. 

Critics of this move have called the Health Survey the “Gold Standard”. Conversely, Rhodes hails the GSGB as a world-class game-changer. That may turn out to be the case, but for now its results need to be approached with a few grains of salt.

What about the White Paper Review?

In his speech, Rhodes makes an early promise to provide “an update on the Gambling Act Review, as much as we can”. However, at least in the published text version of his speech, published by the Gambling Commission, this never really arrives. 

Instead, he simply signs off with a quick mention that there is more work to be done on the Gambling Review’s implementation. There’s no real mention of the recently introduced and highly contentious affordability checks and stake limits on slots. 

It may simply be the case that it’s too soon to tell whether these measures have had an impact, but there are likely to be many at the Briefing who were expecting some acknowledgement. 

Summary

There are some key areas that Rhodes and the Commission seem to be aware of needing additional attention, such as illegal gambling. Notable omissions from the speech include mention of recent, significant policy changes. 

Generally speaking, the Commission appears to be in relatively good shape, with a few worthy victories under its belt, namely the Gambling Survey for Great Britain and GamProtect. Rhodes is right to focus on an approach governed by collaboration, communication and transparency.